Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Disallowance of set off and carry forward of Long Term Capital Loss of sale of quoted equity shares (STT paid) against LTCG arising on sale of property - the income contemplated u/s 10(38) was only a part of the source of capital gains on shares and only a limited portion of source was treated as exempt and not the entire capital gains. - carry forward allowed.
Disallowance of set off and carry forward of Long Term Capital Loss of sale of quoted equity shares (STT paid) against LTCG arising on sale of property - the income contemplated u/s 10(38) was only a part of the source of capital gains on shares and only a limited portion of source was treated as exempt and not the entire capital gains. - carry forward allowed.
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